FCA US LLC Testimony on: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium-and Heavy- Duty Engines and Vehicles- Phase 2 August 6, 2015 Palmer House Hilton Hotel- Chicago, IL

Good Morning, my name is Gary Oshnock; I am the Manager responsible for NAFTA Fuel Economy and Greenhouse Gas Regulatory Compliance at FCA US LLC. The FCA US product lineup features some ofthe world's most recognizable trucks, and engines in this segment. Those trucks include the Class 2 thru 5 variants of our popular Ram pick-ups and our Class 2b ProMaster® commercial vans. Gasoline engines include the award winning 3.6L Pentastar V6 and the 5.7L and 6.4L Hemi®V8 engines. Diesel engines include the class leading 6.7L Cummins®Turbo Diesel16 and our 3.0L EcoDiesel14. Thank you for the opportunity to speak here today and show support for the U.S. EPA (United States Environmental Protection Agency) and NHTSA (National Highway Traffic Safety Administration) efforts to develop the second set of greenhouse gas and fuel consumption rules for the medium and heavy-duty vehicle segment. We fully support and commend this 2019 through 2027 model year Phase 2 initiative, as we did the collaboration that produced the national Phase I rule. FCA US remains committed to the proliferation of clean technology and reducing vehicle operating costs, while ensuring our products continue to deliver the performance and functionality our customers demand and deserve. As EPA and NHTSA noted in the light-duty program, a single National Program "hold[s] out the promise of delivering environmental and energybenefits, cost savings, and administrative efficiencies that might not be available under a less coordinated approach"- FCA US unequivocally agrees. While we are still analyzing the proposed rule, I have a few initial comments and suggestions:

• We support EPA and NHTSA's attribute-based standards that recognize the utility and functionality ofthese work trucks. Payload and towing capacity are importantto the owners ofthese work trucks. These "work factor based" standards acknowledge the inherently higher greenhouse gas emissions and fuel consumption of higher capability vehicles.

• While the light-dutyvehicle fleet has been regulated under NHTSA's CAFE program for roughly forty years, we are still very early in the heavy-duty program. We formally have one full model year of industry data "under our belt."

• Given this limited baseline of real data, it is concerning that there have been calls for even greater stringency beyond the aggressive standards proposed by EPA and NHTSA for Phase 2. Comments regarding stringency need to address the many contributing factors- both explicit and implicit. These factors include, but are not limited to: 1. These work trucks have a wide range of "duty-cycles" so the values of the differenttechnologies vary from a customer perspective. 2. The challenges of year-over-year stringency increases with effectively only two products available to "average" in the 2b/3 segment. 3. The concurrent stringency increases in Tier 3/LEV Ill criteria emission requirements and howto manage the increased thermal loads on aftertreatment systems. 4. The impact of changing test fuels and the test procedure adjustments that will be needed.5. Additional technologies will be needed, given that some Phase 2 techno logies are al ready in the fleet today. (For example, FCA UShas/! cylinder deactivation and cooled EGR in today's vehicles, making these techno logies unavailable for improvements in Phase 2).

• FCA US strongly believes that a single national fuel consumption and greenhouse gas program will place more clean and efficient vehicles on the road quickly and at lower costs. Our resources are best utilized when applied to one, single, national standard versus differing state-level fuel co nsumption and greenhouse gas requirements.

• As far as A/C system improvements, we believe there is value in recognizing the greenhouse gas and fuel consumption contributions from reducing the energy demand of the A/C systems. We also believe there is an additiona l opportunity to further harmonize with the lightduty program and recognize the added greenhouse gas emission benefit, beyond leak reduction, that switching to a lower globa l warming potential refrigerant ca n provide.

• We support the flexibility mechanisms included in the ru le: averaging, banking and trading and recognition ofthe benefits oftechnologies not captured on laboratory drive cycles. We wil l work with the agencies to make these processes more efficient in the second phase oft his program. In closing, FCA US will continue reviewing the proposed rule and submit these and other comments as part ofthe formal rulemaking process. We wi ll work with EPA and NHTSA and other stakeholders to ensure that an implementable rule is finalized on schedule. Thank You.